Letter Sequence Meeting |
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CAC:MF2400, Control Room Habitability (Approved, Closed) |
Initiation
- Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request
- Acceptance...
Administration
- Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting
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MONTHYEARML15274A5992015-10-0101 October 2015 10-01-15 Public Phone Call Project stage: Request ML16011A0612016-02-0202 February 2016 Summary of 10/1/15 Meeting with STP Nuclear Operating Company to Discuss Revised Pilot Submittal and Request for Exemptions for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 at South Texas Project, Units 1 and 2 (CAC Mf Project stage: Meeting ML16028A1522016-02-18018 February 2016 1/14/2016 Summary of Public Meeting with STP Nuclear Operating Company Regarding Modifications to the Licensees Risk-Informed Generic Safety Issue (GSI) 191 Application and Supplements for South Texas Project, Units 1 and 2 Project stage: Meeting ML16088A2432016-04-0101 April 2016 2/18/2016, Summary of Public Meeting with STP Nuclear Operating Company Regarding Open Items, Risk-Informed Generic Safety Issue (GSI) 191 Application and Supplements for South Texas Project, Units 1 and 2 (CAC Nos. MF2400-MF2409) Project stage: Meeting ML16082A5072016-04-11011 April 2016 Request for Additional Information, Phased Response Requested, Exemption and License Amendment Request for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 (CAC Nos. MF2400-MF2409) Project stage: RAI ML16092A0442016-04-11011 April 2016 Summary of 3/3/2016 Public Meeting with STP Nuclear Operating Company Regarding Open Items, Risk-Informed Generic Safety Issue (GSI) 191 Application and Supplements for South Texas Project, Units 1 and 2 (CAC Nos. MF2400-MF2409) Project stage: Meeting ML16095A0102016-04-13013 April 2016 Summary of November 17-19, 2015 Thermal-Hydraulic Review at Texas A&M University; Pilot Submittal and Request for Exemptions for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 (CAC MF2400-MF2409) Project stage: Other ML16092A0852016-04-13013 April 2016 3/17/2016 Summary of Public Meeting with STP Nuclear Operating Company Regarding Open Items, Risk-Informed Generic Safety Issue (GSI) 191 Application and Supplements for South Texas Project, Units 1 and 2 (CAC Nos. MF2401-MF2409) Project stage: Meeting ML16096A0652016-04-13013 April 2016 Summary of February 4 and 16, 2016, Regulatory Audit at Westinghouse in Rockville, MD, Boric Acid Precipitation, Exemption and License Amendment Request, Risk-Informed Approach to Resolve Generic Safety Issue 191 Project stage: Other ML16111A0272016-04-18018 April 2016 STP Nuclear Operating Company Slideshow for Public Meeting on April 21, 2016 for GSI-191 Resolution (CAC No. MF2400-01) Project stage: Meeting ML16032A4032016-04-26026 April 2016 FRN, Draft Environmental Assessment and Finding of No Significant Impact, Revise Licensing Basis as Documented in the UFSAR and Request for Exemptions, Risk-Informed Approach to Address GSI-191 (CAC MF2400-MF2409) Project stage: Draft Other ML16103A3442016-04-26026 April 2016 Summary of February 24-26, 2016 Audit, Debris Transport Review at Alion Science and Technology Corporation, Albuquerque, Nm; Pilot Submittal and Exemption Request, Risk-Informed Approach to Resolve GSI 191 Project stage: Other ML16032A3872016-04-26026 April 2016 Draft Environmental Assessment and Finding of No Significant Impact, Revise Licensing Basis as Documented in the UFSAR and Request for Exemptions, Risk-Informed Approach to Address GSI-191 (CAC MF2400-MF2409) Project stage: Draft Other ML16127A4002016-05-11011 May 2016 Audit Summary, Thermal-Hydraulic Review on February 23-25, 2016 at Texas A&M University; Pilot Submittal and Request for Exemptions for a Risk-Informed Approach to Resolve Generic Safety Issue 191 (CAC MF2400-MF2409) Project stage: Other ML16125A2902016-05-26026 May 2016 Request for Additional Information, Risk Review, Exemption and License Amendment Request for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 (CAC Nos. MF2400-MF2409) Project stage: RAI ML16141B0812016-05-31031 May 2016 Audit Summary, Risk Audit on April 12-13, 2016, at Alumni Center at the University of Texas, Austin, Tx; Pilot Generic Safety Issue 191 Submittal and Exemption Request, and Draft Request for Additional Information Project stage: Draft RAI ML16175A1082016-06-24024 June 2016 Summary of 4/21/2016 Public Meeting with STP Nuclear Operating Company Regarding Open Items, Risk-Informed Generic Safety Issue (GSI) 191 Application and Supplements for South Texas Project, Units 1 and 2 Project stage: Meeting ML16190A0082016-07-13013 July 2016 Summary of 6/22/2016 Public Meeting with STP Nuclear Operating Company Regarding Open Items, Risk-Informed Generic Safety Issue (GSI) 191 Application and Supplements for South Texas Project, Units 1 and 2 (CAC Nos. MF2400-MF2409) Project stage: Meeting ML16200A4172016-07-18018 July 2016 Single Positive Test Form Collected on 08/25/2015 Project stage: Request ML16194A2342016-07-21021 July 2016 Request for Withholding Information from Public Disclosure - 5/6/16 Affidavit Executed by D. Munoz and M. Rozboril, Alion Science and Technology, Response to Follow-up RAIs 18, 38, and 44 Project stage: RAI ML16242A0102016-08-23023 August 2016 NRR E-mail Capture - (External_Sender) FW: South Texas Project GSI-191 Draft Risk Responses to Questions for Public Meeting on August 29, 2016 Project stage: Request ML16242A0092016-08-25025 August 2016 NRR E-mail Capture - (External_Sender) South Texas Project GSI-191 Draft thermal-hydraulic Responses to Questions for Public Meeting on August 29, 2016 Project stage: Request ML16238A5272016-09-0101 September 2016 Summary of 7/28/16, Public Meeting with STP Nuclear Operating Company to Discuss the License Amendment and Exemption Requests to Use a Risk-Informed Approach to the Resolution of GSI-191 (CAC Nos. MF2400 - MF2409) Project stage: Meeting ML16258A3672016-09-0606 September 2016 NRR E-mail Capture - (External_Sender) South Texas Project Generic Safety Issue 191 Resolution SNPB-3-2, Bullet 4 16 -inch Bounding Break Clarification for September 14, 2016 Public Meeting Project stage: Request ML16258A1042016-09-12012 September 2016 NRR E-mail Capture - (External_Sender) South Texas Project Generic Safety Issue 191 Resolution RAI SNPB-3-13 Clarification for September 14, 2016 Public Meeting Project stage: Request ML16258A1002016-09-12012 September 2016 NRR E-mail Capture - (External_Sender) South Texas Project Generic Safety Issue 191 Resolution RAI APLA-3-2 Clarification for September 14, 2016 Public Meeting Project stage: Request ML16258A0982016-09-13013 September 2016 NRR E-mail Capture - (External_Sender) South Texas Project Generic Safety Issue 191 Resolution RAI 33 Clarification for September 14, 2016 Public Meeting Project stage: Request ML16258A0962016-09-13013 September 2016 NRR E-mail Capture - (External_Sender) South Texas Project Generic Safety Issue 191 Resolution RAI SSIB-3-4 Clarification for September 14, 2016 Public Meeting Project stage: Request ML16258A2072016-09-14014 September 2016 NRR E-mail Capture - (External_Sender) South Texas Project Generic Safety Issue 191 Resolution RAI 37 Clarification for September 14, 2016 Public Meeting Project stage: Request ML16258A2082016-09-14014 September 2016 NRR E-mail Capture - (External_Sender) South Texas Project Generic Safety Issue 191 Resolution RAI 34 Clarification for September 14, 2016 Public Meeting Project stage: Request ML16246A0222016-10-0505 October 2016 Summary of Public Meeting with STP Nuclear Operating Company Regarding Open Items Related to Risk-Informed Generic Safety Issue (GSI) 191 Application and Supplements for South Texas Project, Units 1 and 2 (CAC Nos. MF2400 - MF2409) Project stage: Meeting ML16279A3312016-10-27027 October 2016 Summary of Public Meeting with STP Nuclear Operating Company Regarding Open Items, Risk-Informed Generic Safety Issue (GSI) 191 Application and Supplements for South Texas Project, Units 1 and 2 (CAC Nos. MF2400-MF2409) Project stage: Meeting ML16302A4532016-12-12012 December 2016 Closeout of Request for Additional Information Questions That Are No Longer Applicable, Resolution of Generic Safety Issue (GSI) 191 (CAC Nos. MF2400-MF2409) Project stage: RAI ML16351A1502016-12-16016 December 2016 Correction Letter Closeout of Request for Information Questions That Are No Longer Applicable Associated with the Resolution of Generic Safety Issue 191 (CAC Nos. MF2400 - MF2409) Project stage: RAI ML16278A5982017-05-0202 May 2017 Letter, Environmental Assessment and Finding of No Significant Impact, Revise Licensing Basis as Documented in the UFSAR and Request for Exemptions, Risk-Informed Approach to Address GSI-191 (CAC MF2400 to MF2409) Project stage: Other ML16278A5992017-05-0202 May 2017 Environmental Assessment and Finding of No Significant Impact, Revise Licensing Basis as Documented in the UFSAR and Request for Exemptions, Risk-Informed Approach to Address GSI-191 (CAC MF2400 to MF2409) Project stage: Other ML17132A1702017-05-17017 May 2017 Report of Individual Monitoring Project stage: Request ML17137A3252017-05-17017 May 2017 Safety Evaluation of LAR by South Texas Project Nuclear Operating Company to Adopt a Risk-Informed Resolution of Generic Safety Issue-191 Project stage: Approval ML17151A8432017-06-16016 June 2017 OEDO-17-00326 - EDO Response to ACRS Chairman, Safety Evaluation of License Amendment Request by STP Nuclear Operating Company to Adopt a Risk-Informed Resolution of Generic Safety Issue-191 Project stage: Approval ML17055A5002017-07-11011 July 2017 Enclosure 4 to Amendment Nos. 212 and 198, Resolution of Licensee Comments on Safety Evaluation - Risk-Informed Approach to Resolve Generic Safety Issue 191 Project stage: Approval ML17019A0032017-07-11011 July 2017 Attachment 2 to Safety Evaluation - In-Vessel Thermal-Hydraulic Analysis, Issuance of Amendment Nos. 212 and 198 - Risk-Informed Approach to Resolve Generic Safety Issue 191 Project stage: Approval ML17038A2232017-07-11011 July 2017 Issuance of Amendment Nos. 212 and 198 - Risk-Informed Approach to Resolve Generic Safety Issue 191 Project stage: Approval ML17019A0022017-07-11011 July 2017 Safety Evaluation, Enclosure 3 to Amendment Nos. 212 and 198 - Risk-Informed Approach to Resolve Generic Safety Issue 191 Project stage: Approval 2016-05-31
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EPOXY COATINGS IN THE REACTOR CAVITY - STP 4-18-2016 Page 1 of 9 Quantity of Coatings 1,570 lbs of epoxy coatings on the concrete walls and ceilings Unit 1 has a larger quantity since the Unit 2 walls are not epoxy coated all the way up to the ceiling and also since the ceilings in Unit 2 are not epoxy coated.
The sump performance evaluation is based on the higher quantity for Unit 1.
The Reactor Cavity is designated as Reactor Containment Building Room 001.
EPOXY COATINGS IN THE REACTOR CAVITY - STP 4-18-2016 Page 2 of 9 Type of Coatings Brown and Root Technical Reference Document 5A810WQ005-A Painting Schedule for Service Level I, II, and III Areas from 1979 calls for the Reactor Cavity walls to be coated using the following Level I concrete coating system defined in HL&P Specification #7A810XS002-A-HL:
Nutec 10 Primer/Sealer Nutec #11S Concrete Masonry/Surfacer Nutec #11 Concrete Masonry/Surfacer Reactic (Nutec) #1201 Epoxy Topcoat Service History Just prior to the initial startup of Unit 1 in 1987 during hot functional testing, repairs were made to the concrete wall coating in the Reactor Cavity. Cracks in the originally installed coating were chased and the adjacent coating was removed. These areas were not top-coated due to the unavailability of that coating at the time. Instead the areas were left with only a base sealer. See Unit 1 photographs.
No other evidence has been found of any repairs since then in Unit 1. Also Unit 2 had no evidence found of any repairs since the startup of the Unit in 1989. A search of work order history and a search of condition reports did not yield any repair requests or coating conditions in either Unit.
The maintenance work planner who has been dealing with coatings since startup was not aware of Similar discussion with Engineering personnel who perform Reactor Vessel inspections in Room 001 also did not yield any information concerning coating problems.
As seen in the photographs, the current condition of the coatings in both Units appears good.
EPOXY COATINGS IN THE REACTOR CAVITY - STP 4-18-2016 Page 3 of 9 Current Condition Based on Photographs of the Area Unit 1 Photos
EPOXY COATINGS IN THE REACTOR CAVITY - STP 4-18-2016 Page 4 of 9 Unit 1 Photos
EPOXY COATINGS IN THE REACTOR CAVITY - STP 4-18-2016 Page 5 of 9 Unit 2 Photos from 2013
EPOXY COATINGS IN THE REACTOR CAVITY - STP 4-18-2016 Page 6 of 9
EPOXY COATINGS IN THE REACTOR CAVITY - STP 4-18-2016 Page 7 of 9 Manufacturer Qualification Data The test document from Southern Imperial Coatings (filed as STI 525724) states that the Nutec 11/ 11S/ 1201 was qualified to 2E08 rads which is consistent with IEEE STD 323-1974 for normal plus LOCA dose.
However, the epoxy coating for the reactor cavity was deemed by Bechtel during the unqualified coating calculation rack up to be unqualified due to the excessive calculated cumulative radiation dose.
EPOXY COATINGS IN THE REACTOR CAVITY - STP 4-18-2016 Page 8 of 9 Cumulative Dose Received The epoxy coating for the reactor cavity was deemed to be unqualified due to excessive radiation.
From design criteria document 4E019NQ1009:
The calculated cumulative design dose for the Reactor Cavity for 40 years is:
Neutron 2.5E10 Rads Gamma 3.5E9 Rads The accident dose is given as 1.5E8 Rads.
The calculated cumulative dose was determined considering the reactor operated at 100% power every day for 40 years.
The actual capacity factor for each Unit to date is:
Unit 1 83.7%
from initial operation in 1988 to March 2016 (28 years)
Unit 2 83.2%
from initial operation in 1989 to March 2016 (27 years)
Thus the actual cumulative dose to date is:
= capacity factor x (operating years / design life years) x calculated lifetime dose
= 0.8 x (28/40) x calculated lifetime dose
= 0.56 x calculated lifetime dose Coatings Assessment The epoxy coatings in the Reactor Cavity (RCB Room 001) in both Unit 1 and in Unit 2 were applied as Service Level I coatings during the construction phase of the plant. However, these epoxy coatings for the reactor cavity were subsequently deemed to be unqualified due to the excessive calculated cumulative radiation dose. They were not part of the qualified coatings inspection program and there was no continuity of inspections.
The epoxy coatings in the Reactor Cavity in both Unit 1 and in Unit 2 are now deemed as Qualified But Degraded based upon consideration of the following:
- Initial application was safety related (Service Level I)
- No historical evidence of coating problem conditions requiring repairs since installation
- Recent visual observation (photos and personnel observations) shows no signs of degradation
- Estimated cumulative dose to date is over half of the calculated cumulative dose but no current signs of degradation
- Estimated cumulative dose to date exceeds the test qualification value but no current signs of degradation
EPOXY COATINGS IN THE REACTOR CAVITY - STP 4-18-2016 Page 9 of 9 EPRI Report 1014884 Plant Support Engineering: Degradation Research for Nuclear Service Level I Coatings concludes that the majority of coating failures and signs of degradation can be attributed to undetected deficiencies that occurred at the time of coating application. These deficiencies are the major cause of coating deterioration during the coating systems service life.
The report also states that high radiation is not believed to be a significant cause of coating degradation in containment.
Since the epoxy coatings in the Reactor Cavity in both Units have been in service for over half of their design life with no signs of degradation, any degradation in the future is not expected.
Thus these coatings are considered Qualified But Degraded.
Debris Characteristics The Reactor Cavity epoxy coatings are considered as Qualified But Degraded and are assumed to fail as chips with the following debris characteristics:
Range (inches)
Weight Distribution (%)
1.0 - 2.0 32.0 0.5 - 1.0 9.04 0.25 - 0.50 4.41 0.125 - 0.25 5.02
< 0.125 37.1 as 15.6 mils chips; 12.3 as 6 mils particulate Transport Evaluation No transport is expected for epoxy coating debris inside the reactor cavity for breaks that do not occur within the reactor cavity because
- for breaks that occur outside the reactor cavity, there is no flow into the reactor cavity,
- the path out of the reactor cavity is sufficiently tortuous that this area will be essentially stagnant, and
- any negligible flow from the reactor cavity that could occur will be to a region on the opposite side of the steam generator compartment from where the sumps are located.
For breaks inside the Reactor Cavity (i.e. at the reactor Vessel nozzle), most of the epoxy coating debris will fail as chips. A portion of the debris that is fine chips and the portion that is particulate is subject to transport. The transport path out of Room 001 is through two 4 inch floor drains in the Reactor Cavity floor that go to the Normal Sump. This sump has a cover plate with an opening for water to go out onto the floor when the sump is full. Thus there will be some transport from the Reactor Cavity to the containment pool.